I believe our bank is going to subject to HMDA some time this year. I know from listening to others that this is a hard reg to get right. I have several questions:

1. If we become subject to HMDA mid-year, will we have to report activity going back to 1/1/12 or just from the period that we are subject to the regulation?

2. Any recommendations on training resources?

3. Any recommendations on HMDA software solutions?

1. If you become subject to HMDA this year, you start collecting and reporting as of 1/1/13.

2. The Guide to HMDA reporting, is HMDA - Getting it right book, or HMDA GIR, and it will be your bible. Find it at www.ffiec.com/hmda/default.htm

3. Don't really have a recommendation. The ffiec free software would probably fine for a small LAR.

To tag onto #12, the GIR is THE source, but you need to really read it, especially the commentary and definitions. Also, be aware that a lot of loan situations don't fit into a nice neat box when it comes to coding the HMDA LAR, so document your files on why you coded the squirrelly loans the way you did. Come up with written how-to procedures so everyone will code things consistently (ie what income to use, where to find it, etc).

And visit this forum often!

Good luck!

BOL also has a nice flowchart for the more straight forward determinations of HMDA reportability:

http://www.bankersonline.com/compliance/2004_HMDA_Flowchart.pdf

One more suggestion, especially if you will have a relatively small LAR....hand enter them yourself onto the D(ata)E(ntry)S(oftware) if at all possible, instead of drawing them in from your LOS. My first year of HMDA reporting caused me a lot of heartache because of errors in the LOS that i couldn't control.

as far as training goes, Professional Bank Services puts on an excellent Mastering HDMA seminar that hands out a great book to use as a reference tool.

as soon as they announce the new fields, i will be heading back to this seminar.

i have a pdf of the book if you would like to pm me your email annd ill send it to you

and GOOD LUCK :))

Some handy links--
and of course, the BOL HMDA forum.

http://www.ffiec.gov/hmda/pdf/2010guide.pdf
Save to your computer and use the search feature.

http://www.ffiec.gov/hmdaadwebreport/diswelcome.aspx
You will need this one when the reports are ready.

http://www.ffiec.gov/hmda/default.htm

http://www.ams.org/profession/data/other-sources/Race_Ethnicity_Definitions.pdf